Permit me to introduce you to
Douglas Williams, the owner ofPolygraph.com. Instead of writing a lengthy introduction about Mr. Williams,
how about I let him speak for himself:

Frankly, the video is pretty
straightforward. Williams, a former Oklahoma City law enforcement officer,
proclaims that he is the:

only
licensed polygraph examiner to ever tell the truth about the so-called lie
detector. The truth is a polygraph is not a lie detector. Truthful people are
often branded as liars; and liars often pass easily.

Williams calls a polygraph
examination "just a sick joke," and he admonishes that the lie
detector doesn't so much detect lying as it does nervousness -- and he can
teach you how to not be nervous during the exam. As he
promises

I will get
you ready to pass your polygraph test and you will not have to be frightened or
nervous about taking it.

Given that pitch, I'm sure that a lot of folks
faced with the dread lie detector test rushed to pay Williams so that they were not be detected as lying when, in fact, as he explained, they were just nervous. You
shouldn't think that business plan would get anyone in all that much trouble,
right?

Indictment

On November 14, 2014,
Williams was charged in federal court in the Western District of Oklahoma on two
counts of mail fraud and three counts of witness tampering.
The Indictment alleged that as a result of training
provided by Williams, certain Polygraph.com customers were provided with techniques that would
purportedly help them evade detection for lying during polygraph exams
administered by federal-, intelligence-, state-, and local-law enforcement
agencies, as well as during exams administered pursuant to terms of parole or probation.in connection with his alleged
training of customers. In United States of America, Plaintiff,
v. Douglas G. Williams, Defendant (Indictment, WDOK, 14-CR-318, November 13,
2014).

Undetected Imposters

One
of the individuals purportedly trained by Williams was posing as a federal law
enforcement officer, and Williams allegedly trained him with the goal of
helping him conceal criminal activity during an internal agency investigation.
In another example, a second individual posing as a federal job-seeker was
trained to conceal crimes during a pre-employment exam. For example, consider these
assertions in the Indictment:

37.
During the training, Undercover B said to WILLIAMS, ''My big fear is them
asking me about the drug question," at which time WILLIAMS interrupted
again, saying, "Oh, God, please help me. Brian, shut the fuck up about
worrying about stuff. Listen to me .... I was just getting to the solution to
your fucking worries .... I've already told you three times, 'quit bringing up
negative shit, because I'm fixing it to put it all positive, okay?"
WILLIAMS added, "I don't give a damn if you're the biggest heroin dealer
in the fucking United States."

38. During the training, WILLIAMS
told Undercover B that he (Undercover B) would have to think of scenarios that
would cause him (Undercover B) to have a "fearful, nervous, scared-type
reaction." Undercover B said, "l got two things. When I was a jailer,
I smuggled cocaine into the jail for an inmate." WILLIAMS replied,
"Let's don't think about that. What else? What's the other one?"
Undercover B responded, "I had to go to the high school to pick up a
student because she was involved in drugs, took her to the station, interviewed
her, and on the way back we kind of messed around." 15 Case
5:14-cr-00318-M Document 1 Filed 11/13/14 Page 15 of 21 WILLIAMS responded,
"Okay, we're not gonna think about that one either." WILLIAMS
explained, ''We don't want to think about something that you're lying about,
because we don't want you to even think about that, those questions."
WILLIAMS told Undercover B, "I'm just wanting you not to think of
something that's incriminating."

39. Undercover B later asked WILLIAMS, "If I tell
them that I sold drugs in the jail, when I was a jailer, can they use that
against me? ... I'm certainly not gonna tell them I got a blow job from a 14-year-old
girL" WILLIAMS responded, "Keep that shit to yourself. I mean, why
would you ever say something like that anyway? If you're gonna do that, save
yourself the trouble, don't even go. If you're gonna sabotage your own damn
self." WILLIAMS then said, ''Why would you ever tell 'em sons of bitches
anything that you don't want 'em to know?"

40. After telling Undercover B not to admit anything that
he (Undercover B) did not want the Federal government to know, WILLIAMS said,
"A lot of times they'll say, 'You're having trouble with this drug
question. You're having ... There's something else you need to tell me Brian.'
You just look at him and say, 'Sir, I have told you the absolute, complete
truth.' ... You throw it right back on him. And you do not make any admissions
whatsoever." Undercover B told WILLIAMS, "I just don't want Internal
Affairs to open up a big investigation," and WILLIAMS responded, ''We're
not gonna worry about that because you're not going to have a reaction. I'm
showing you, right now. You always get ahead of me. I can solve these
problems."

On
May 13, 2015, Williams pled guilty to obstruction of justice and mail fraud.

Bill
Singer's
Comment

A truly interesting and
provocative case. We're seeing a lot more so-called "cheating" cases
popping up all over -- be that allegations against Tom Brady and the New
England Patriots for deflating footballs or the recent convictions of 11
Atlanta, GA, educators for helping students to cheat on standardized testing. In recent years, the
BrokeAndBroker.com Blog has reported about numerous cases involving cheating on securities industry registration or
continuing education
exams.

An interesting thought piece is
whether Williams could have merely altered his business model and avoided the
criminal charges.

For example, imagine that
Williams prepares videos and printed materials that assert his position that
lie detectors only detect nervousness and not lies. He then posits that in his
professional experience, many honest folks become so nervous during polygraph
exams, that their answers are perceived as lies and they fail to get the job
offer. Similarly, Williams opines that many crooks are skilled liars and walk
into a polygraph exam knowing it's all bull-shit and if they just stay calm,
they will pass with flying colors. Based upon those two premises, Williams then
offers to sell you a DVD or give you password access to an online video in
which he promises to teach you how to stay calm during polygraph exams so that
the "truth will come out." He
pointedly admonishes that these course are not intended to train liars to come
off as truthful and under no circumstances should job applicant use his methods
to avoid detection of their criminal histories by future employers.

In truth and fairness, the above
approach is NOT what Williams pursued and the Indictment
strongly paints the picture that he knew that he was aiding and
abetting job applicants to hide their criminal pasts. On the other hand, we should be alert as to
just where the line is drawn in circumstances where folks are offering
"training" in preparation for an important examination or test. At
what point, for example, does test preparation cross the line from
"gaming" the system and into cheating? Williams may offer an
answer but how far could he have gone before his conduct became
criminal?

BILL SINGER is a lawyer who represents securities-industry firms, individual registered persons, Wall Street whistleblowers, and defrauded public investors. For over three decades, Singer has represented clients before the American Stock Exchange, the New York Stock Exchange, the Financial Industry Regulatory Authority (formerly the NASD), the United States Securities and Exchange Commission, and in criminal investigations brought by various federal, state, and local prosecutors. He has the distinction of representing witnesses during Congressional investigations. In 2015, Singer achieved a significant award in excess of $1 million from the Securities and Exchange Commission on behalf of a whistleblower client.

Singer is presently Of Counsel to a law firm and the publisher of the BrokeAndBroker.com Blog, which was rated as one of the industry's top eight destination websites and the leading legal/regulatory blog by "Investment News."

Before entering the private practice of law, Singer was employed in the Legal Department of Smith Barney, Harris Upham & Co.; as a regulatory attorney with both the American Stock Exchange and the NASD (now FINRA); and as a Legal Counsel to Integrated Resources Asset Management. Singer was formerly Chief Counsel to the Financial Industry Association; General Counsel to the NASD Dissidents' Grassroots Movement; and General Counsel to the Independent Broker-Dealer Association. He was registered for a number of years as a Series 7 and Series 63 stockbroker.

Singer regularly appears as a commentator on television and radio, and is frequently quoted in the press. He is an outspoken critic of ineffective regulation and an advocate for economic and political sanity.